State v. Guild

Citations

• 353 Conn. 76

Syllabus

The acquittee, who had been found not guilty of certain crimes by reason of mental disease or defect, was committed to the jurisdiction of the Psychiatric 353 Conn. 76 AUGUST, 2025 77 State v. Guild Security Review Board in 1999, for a period not to exceed twenty years. The acquittee's commitment was extended multiple times since the expiration of his initial term of commitment. In 2022, the state filed a petition to extend the acquittee's commitment pursuant to statute (§ 17a-593 (c)). The acquittee moved to dismiss the state's 2022 petition on the ground that the commitment procedure set forth in § 17a-593 (c) violated his right to equal protection under the United States constitution, but the trial court denied the acquittee's motion to dismiss and, in 2023, granted the state's petition, extending the acquittee's commitment for two more years, until 2025. The acquittee then appealed from the trial court's 2023 order extending his commitment until 2025. In 2024, prior to oral argument before this court, the state filed another petition with the trial court, which, if granted, would have extended the acquittee's commitment beyond 2025. In response to that petition, the board filed a report recommending that the trial court deny the state's 2024 petition because the acquittee was no longer a danger to himself or others. The state ultimately withdrew its 2024 petition, which resulted in the acquittee's discharge from the jurisdiction of the board while this appeal was pending, in March, 2025. Held: Because the acquittee was discharged from the custody of the board during the pendency of this appeal, the appeal was rendered moot. Contrary to the acquittee's claim, the collateral consequences doctrine did not save the acquittee's appeal from being dismissed as moot, as the 2023 commitment order constituted an extension of several, prior commitments beyond the acquittee's initial twenty year term that all stemmed from one acquittal, and this court did not see how the 20